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Residence & domicile

A non-domiciled and non-resident individual who created an offshore trust has recently died. Will distributions to the UK resident and domiciled beneficiaries be treated as capital or income and will the defence in ITA 2007, s 739 be applicable? And should the trust now become UK resident itself?
MALCOLM FINNEY considers the implications of non-UK domiciles accessing offshore monies following FA 2008
MIKE TRUMAN reports on the High Court judgment in the Grace case
Offshore trusts: are they still shipshape, or have they been fatally holed below the waterline, asks LOUISE SOMERSET
MIKE TRUMAN and CHARLENE CHOI listened to the arguments in court as HMRC appealed the taxpayer's win in Grace
Special Commissioner overturned for first time in 100 years
Majority have no firm policies in place: study
DAVID TREITEL explains tax for the American living in the UK
TIM KEELEY urges advisers to ensure that claiming the remittance basis will be advantageous
HMRC deadline is 15 December
RICHARD CURTIS reviews the 21st and 22nd sittings of the Public Bill Committee's deliberations on Finance Bill 2008
Even for non-domiciliaries with quite straightforward financial affairs, the new remittance rules are monstrously complicated and opaque, warns SIMON MCKIE
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